DETAILED ACTION
Status of Claims
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
This action is in reply to the amendment filed on 06/12/2026.
Claim 19 has been cancelled.
Claims 1-18, and 20-21 are currently pending and have been examined.
Response to Arguments
Applicant’s arguments, see page 12, filed 06/12/2026, with respect to claims 1-18 and 20-21 have been fully considered and are persuasive. The 103 rejections of claims 1-18 and 20-21 has been withdrawn.
Applicant's arguments filed 06/12/2026 with respect to the 35 USC 101 have been fully considered but they are not persuasive.
Applicant argues #1:
Applicant respectfully submits that the amended claims are not directed merely to commercial or legal interactions, as alleged by the Office Action. Rather, the amended claims recite a specific computer-implemented transaction-processing architecture that dynamically evaluates jurisdiction-specific regulatory parameters within a configurable transaction array for accuracy and responsively updates parameter fields used for downstream automated regulatory enforcement and transaction-halting operations.
The newly added "determining" step is not a generic mental process or mere data analysis. Instead, the determining operation is integrated into a specialised configurable transaction-array architecture in which:
i) jurisdiction-specific regulatory parameters are selectively mapped into a
configurable transaction array based on sender and receiver information;
ii) the system dynamically determines whether such mapped regulatory
parameters require updating; and
iii) one or more parameter fields of the configurable transaction array are
responsively updated prior to automated enforcement using a populated
decision tree.
Accordingly, the amended claims improve computerised jurisdiction-dependent transaction processing by the dynamic transaction-specific regulatory parameter evaluation and configurable transaction-array updating prior to automated enforcement operations.
Examiners response:
Examiner respectfully disagrees, mapping the parameters according to the transaction information and determining if the parameters need to be updated/updating the parameters and processing the transaction accordingly is still directed towards the abstract idea, further defining the abstract idea akin to Performing repetitive calculations, Flook, 437 U.S. at 594, 198 USPQ2d at 199 (recomputing or readjusting alarm limit values); Bancorp Services v. Sun Life, 687 F.3d 1266, 1278, 103 USPQ2d 1425, 1433 (Fed. Cir. 2012) ("The computer required by some of Bancorp’s claims is employed only for its most basic function, the performance of repetitive calculations, and as such does not impose meaningful limits on the scope of those claims."); and Electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 225, 110 USPQ2d 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, 772 F.3d at 716, 112 USPQ2d at 1755 (updating an activity log);. Further, this is akin to Intellectual Ventures I v. Capital One Fin. Corp., 850 F.3d 1332, 121 USPQ2d 1940 (Fed. Cir. 2017), in which the steps in the claims described "the creation of a dynamic document based upon ‘management record types’ and ‘primary record types.’" 850 F.3d at 1339-40; 121 USPQ2d at 1945-46. The claims were found to be directed to the abstract idea of "collecting, displaying, and manipulating data." 850 F.3d at 1340; 121 USPQ2d at 1946, and amounted to no more than instructions to apply the abstract idea, similar to the instant application which is collecting, analyzing, and manipulating data related to update and create a jurisdictional file and transaction array for analyzing transactions and financial regulatory requirements of countries and halting the transaction (a commercial interaction). See also Providing historical usage information to users while they are inputting data, in order to improve the quality and organization of information added to a database, because "an improvement to the information stored by a database is not equivalent to an improvement in the database’s functionality," BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287-88, 127 USPQ2d 1688, 1693-94 (Fed. Cir. 2018);.
Applicant argues #2:
Further, the presently claimed invention is not merely directed to "collecting, analyzing, and manipulating data," as alleged by the Office Action. Instead, the claims recite a specific manner of configuring, evaluating, and updating a configurable transaction array used to control automated transaction-processing operations and transaction halting decisions.
The claims, therefore, integrate any alleged abstract idea into a practical application by improving operation of computerized financial-regulatory transaction-processing systems through: selective mapping of jurisdiction-specific regulatory parameters; determination- driven configurable transaction-array updating; and automated enforcement using populated decision-tree processing.
Further, the claims recite significantly more than generic computer implementation. The claimed configurable transaction-array architecture, selective mapping operations, determination-driven parameter updating operations, and populated decision-tree enforcement operations collectively amount to a specific technological implementation for improving computerised financial-regulatory transaction processing across multiple jurisdictions. The claimed subject matter improves efficiency, accuracy, and consistency of automated multi-jurisdictional compliance processing and downstream decision-tree-based transaction enforcement.
Accordingly, the claims are not directed to merely organizing human activity or performing generic computer functions. Rather, the claims recite a specific improvement in computerised transaction-processing systems and therefore are patent eligible under 35 U.S.C. § 101.
Examiners response:
The Examiner respectfully disagrees, with regards applicant’s arguments that the claims are integrated into a practical application and amount to a technical improvement, the Examiner fails to see how the claims indicative of a practical application or amount to a technical improvement, as laid out in MPEP 2106.04(d), as they fail to provide:
Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition – see Vanda Memo
Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing - see MPEP 2106.05(c)
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP 2106.05(e) and Vanda Memo
Here the claims only recite abstract steps being applied with generic computer components. Mere instructions to apply the judicial exception using generic computer components is not indicative of a practical application (see MPEP 20106.05(f)). Further with respect to the claims operations of computerized financial-regulatory transaction-processing systems through: selective mapping of jurisdiction-specific regulatory parameters; determination- driven configurable transaction-array updating; and automated enforcement using populated decision-tree processing, this does not amount to technical improvement or practical application as per MPEP 2106.05(f) Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more. See Affinity Labs v. DirecTV, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016) (cellular telephone);, and as shown in MPEP 2106.05, Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) and Performing repetitive calculations, Flook, 437 U.S. at 594, 198 USPQ2d at 199 (recomputing or readjusting alarm limit values); Bancorp Services v. Sun Life, 687 F.3d 1266, 1278, 103 USPQ2d 1425, 1433 (Fed. Cir. 2012) ("The computer required by some of Bancorp’s claims is employed only for its most basic function, the performance of repetitive calculations, and as such does not impose meaningful limits on the scope of those claims."); is not a technical improvement similar the instant application which arranges and updates the configurable transaction array, generated based on transaction-specific data and updated based on the sender and receiver jurisdictional mapping to enforce logic through a populated decision tree for analyzing a transaction.
For the reasons above, the 101 rejection is hereby maintained.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-18, and 20-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more, and fails step 2 of the analysis because the focus of the claims is not on the devices themselves or a practical application but rather directed towards an abstract idea, the analysis is provided below.
Step 1 (Statutory Categories) - The claims pass step 1 of the subject matter eligibility test (see MPEP 2106(III)) as the claims are directed towards a system, and two methods.
Step 2A – Prong One (Do the claims recite an abstract idea?)
The idea is recited in the claims 1 and 8, in part, by:
generating a jurisdictional definition file based on a plurality of financial regulatory requirements for a plurality of countries;
responsive to receiving a transaction request, generating a configurable transaction array for the transaction request that is a subset of the jurisdictional definition file based on a sender information and a receiver information;
mapping the sender information and the receiver information into the configurable transaction array;
the configurable transaction array comprises jurisdiction-specific regulatory parameters selectively mapped to the transaction request;
determining whether the jurisdiction-specific regulatory parameters of the configurable transaction array are updated based on the selective mapping;
updating one or more parameter fields in the configurable transaction array in responsive to the determining based on the selectively mapped jurisdiction-specific regulatory parameters;
enforcing the one or more financial regulatory requirements defined by the configurable transaction array based on the updated configurable transaction array;
halting a transaction based on the enforcing using a decision tree that is populated by the configurable transaction array.
While varying in scope, claim 15 recites an idea, in part by:
generating a jurisdictional definition file based on a plurality of financial regulatory requirements for a plurality of countries;
responsive to receiving a transaction request, generating transaction data comprising one or more questions that are based on a sender information and a receiver information of the transaction request, the transaction data further comprising jurisdiction-specific regulatory parameters selectively mapped to the transaction request;
determining whether the jurisdiction-specific regulatory parameters of the configurable transaction array are updated based on the selective mapping;
updating one or more parameter fields in the transaction data in responsive to the determining based on the selectively mapped jurisdiction-specific regulatory parameters;
enforcing the one or more financial regulatory requirements based on the updated transaction data
halting a transaction based on the enforcing using a decision tree that is generated from the transaction data.
The steps recited above under Step 2A Prong One of the analysis under the broadest reasonable interpretation covers commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations) but for the recitation of generic computer components for halting a transaction based on financial regulatory requirements. That is other than reciting a jurisdictional definition system comprising a processor, nothing in the claim elements are directed towards anything other than commercial or legal interactions. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions, then it falls within the “Certain Methods of Organizing Human Activities” groupings of abstract ideas. Accordingly, the claims recite an abstract idea.
Step 2A – Prong Two (Does the claim recite additional elements that integrate the judicial exception into a practical application?) - This judicial exception is not integrated into a practical application. In particular, the claims only recite the additional elements of a jurisdictional definition system comprising a processor. The jurisdictional definition system comprising a processor is recited at a high level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply the judicial exception using generic computer components is not indicative of a practical application (see MPEP 20106.05(f)). The specification does not provide any indication that the jurisdictional definition system comprising a processor is other than generic computer components and acknowledges that the “The jurisdictional system 100 may include one or more computer hardware systems… The jurisdictional definition system 105 includes a processor 125,memory 130,data extraction module 135” describing a highly generic computer components. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims are directed towards an abstract idea.
Step 2B (Does the claim recite additional elements that amount to significantly more than the judicial exception?) - The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, as discussed above, with respect to integration of the abstract idea into a practical application, using the additional elements of a jurisdictional definition system comprising a processor to perform the steps recited in Step 2A Prong One of the analysis amounts to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components does not provide an inventive concept. The additional elements have been considered separately, and as an ordered combination, and do not add significantly more (also known as an “inventive concept”) to the judicial exception. Further, similar to Intellectual Ventures I v. Capital One Fin. Corp., 850 F.3d 1332, 121 USPQ2d 1940 (Fed. Cir. 2017), in which the steps in the claims described "the creation of a dynamic document based upon ‘management record types’ and ‘primary record types.’" 850 F.3d at 1339-40; 121 USPQ2d at 1945-46. The claims were found to be directed to the abstract idea of "collecting, displaying, and manipulating data." 850 F.3d at 1340; 121 USPQ2d at 1946, and amounted to no more than instructions to apply the abstract idea, similar to the instant application which is collecting, analyzing, and manipulating data related to create a jurisdictional file and transaction array for analyzing transactions and financial regulatory requirements of countries and halting the transaction (a commercial interaction). Additionally, MPEP 2106.05(d)(ii) provides that receiving and transmitting data over a network (see buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network), and Electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 225, 110 USPQ2d 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, 772 F.3d at 716, 112 USPQ2d at 1755 (updating an activity log); are well-understood routine and conventional, similar to the instant application claims which recites and sending and receiving data over network, and mapping the transaction information to perform the commercial and legal interactions of halting the transaction. The claims are not patent eligible.
The dependent claims have been given the full analysis including analyzing the additional limitations both individually and in combination as a whole. For instance, claims 2-7, 9-14, 16-18, and 20-21 are all steps that fall within the “Certain Methods of Organizing Human Activities” groupings of abstract ideas, further defining abstract ideas, amounting to more than instructions to apply the idea. The Dependent claims when analyzed both individually and in combination are also held to be patent ineligible under 35 U.S.C. 101 for the same reasoning as above and the additional recited limitations fail to establish that the claims are not directed to an abstract idea. The additional limitations of the dependent claims when considered individually and as an ordered combination do not amount to significantly more than the abstract idea.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Harris, et al. (US Patent Application Publication 20210383382) discloses “Additionally, in certain arrangements, the payment rule(s) are automatically updated, while in other arrangements, a notification is sent to the customer recommending that the customer update the payment rule(s), and the customer is responsible for updating the payment rule(s). Further, as discussed above, in some arrangements, the method comprises determining whether the payment rule(s) should be updated whenever a transaction violates the payment rule(s) but is later authorized. Alternatively, in other arrangements, the method comprises determining whether a given payment rule should be updated in response to the payment rule being historically violated (e.g., violated a certain number of times within a given time period) but later authorized.” Agrawal, et al. (US Patent Application Publication 20180350006) discloses “The compliance management processor 542 receives input including, for example, one or more non-compliant scored cases for constant surveillance to help identify misuse and abuse updates and to provide those updates into the rules in the dynamic scoring system. The compliance processor also provides an intervention algorithm to automatically monitor specified card programs and provide suggestions for updates to move the program closer or back into compliance. In an aspect of the invention, the interface 550 may be a web-based, flexible application for commercial payment programs for maximization of savings and benefits by operating according to a company's policies.”
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to GREGORY S CUNNINGHAM II whose telephone number is (313)446-6564. The examiner can normally be reached Mon-Fri 8:30am-4pm.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Bennett Sigmond can be reached at 303-297-4411. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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GREGORY S. CUNNINGHAM II
Primary Examiner
Art Unit 3694
/GREGORY S CUNNINGHAM II/ Primary Examiner, Art Unit 3694
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